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Answer.pdf

3030 S 9Th LLC, Petitioner Vs. Township Of Oshtemo, Respondent · 25-002333-TT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

3030 S 9TH ST LLC., 

 

 

Petitioner, 

 

 

 

 

MOAHR DOCKET NO: 25-00233 

 

 

 

 

 

 

 

(Parcel No: 3905-26-380-046) 

 

v. 

 

OSHTEMO TOWNSHIP, 

 

 

Respondent. 

___________________________________________________________________ 

 

Jon Aylsworth, Property Tax Consultants 

James W. Porter (P38791) 

Representative for Petitioner 

 

Representative for Respondent 

861 Pinecrest Ave SE 

 

 

Oshtemo Charter Township 

Grand Rapids, MI 49506 

 

 

7275 West Main Street 

(269) 366-0300 

 

 

 

Kalamazoo, MI 49009 

 

jack@skylinepropertytax.com 

 

(269) 375-7195 

 

 

 

 

 

 

 

jposhtwp@oshtemo.org 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

___________________________________________________________________ 

 

RESPONDENT’S ANSWER TO PETITIONER’S ENTIRE TAX TRIBUNAL PETITION 

AND AFFIRMATIVE DEFENSES 

 

 

NOW COMES the Respondent, Oshtemo Charter Township, by and through its attorney, 

James W. Porter, and in Answer to the Petition filed in this matter, states as follows: 

1. 

In answer to Paragraph 1 of the Petition, Respondent admits to the allegations 

contained therein. 

2. 

In answer to Paragraph 2 of the Petition, Respondent admits to the allegations 

contained therein. 

3. 

In answer to Paragraph 3 of the Petition, Respondent admits to the allegations 

contained therein.

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4. 

In answer to Paragraph 4 of the Petition, Respondent admits to the allegations 

contained therein. 

5. 

In answer to Paragraph 5 of the Petition, Respondent admits to the allegations 

contained therein. 

6. 

In answer to Paragraph 6 of the Petition, Respondent admits to the allegations 

contained therein. 

7. 

In answer to Paragraph 7 of the Petition, Respondent admits to the allegations 

contained therein. 

8. 

In answer to Paragraph 8 of the Petition, Respondent denies the allegations 

contained herein for the reason the same are untrue. 

9. 

In answer to Paragraph 9 of the Petition, Respondent admits Petitioners contention 

and denies True Cash Value. 

10. 

Respondent respectfully requests that the Tribunal deny Petitioner’s request. 

WHEREFORE, Respondent respectfully requests that the Tribunal deny 

Petitioner’s request and uphold Respondent’s true cash, state equalized and taxable values 

for the subject property. 

 

AFFIRMATIVE DEFENSES 

 

 

 

Please take notice that Respondent may rely upon the following affirmative defenses: 

1. 

The subject property is under-assessed, and taxable value is too low and should be 

set at 50% of its market value, and thereafter, the taxable value should be increased.

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2. 

Respondent reserves the right to file additional affirmative defenses in this matter 

once it has had the opportunity to complete discovery, which opportunity it has not had, given time 

to respond to the Petition. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Respectfully submitted, 

 

 

 

 

 

 

OSHTEMO CHARTER TOWNSHIP 

 

 

Date: July 25, 2025 

 

 

 

By: /s/ James W. Porter________ 

 

 

 

 

 

 

James W. Porter (P38791) 

 

 

 

 

 

 

Attorney for Respondent

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